Frequency Control Task Force

1. Frequency ControlTask Force Report to WMS March 22, 2006

2. Overview • Background / FCTF Charge • Issues Examined by FCTF • Framing the Issues • Options • Next Steps

3. Background • The ERCOT Single Control Area frequently experiences poor system frequency control. • Originally noticed during the morning and evening ramps, frequency excursions actually occur throughout the day. • It was theorized that minimizing generator Schedule Control Error should contribute to an improvement in system frequency control. • Prior to the adoption of PRR 525, resource QSEs were only held to an SCE standard during intervals in which they provided Regulation Service.

4. Background (cont.) • Through PRR 525, stakeholders elected to address poor system frequency control by improving SCE through application of an SCE performance measure to all resource QSEs. • PRR 525 did not address penalties for non-compliance, so the discretionary “death penalty” in Protocols 6.10.12 became the default penalty for failure to meet the metric. • PRR 586 was filed by PUCT Staff to further address SCE through reallocation of Regulation Service costs to resource QSEs with poor SCE.

5. PRS action on PRR 586 • Remanded to ROS 5/19/05 with instructions to: • Frame the issue • Determine whether PRR 586 resolves that issue • Either amend PRR 586 to resolve issue or draft new PRR to resolve issue • Determine any unintended consequences of PRR 586

6. ROS Response on PRR 586 • ROS response to PRS on 7/21/05 framed the technical requirements: • PRR 586 will not solve the frequency problem in ERCOT, but may be part of a broader package of solutions • 420 MW / 0.1 Hz should remain the frequency response standard, applicable to frequency disturbances defined as a Measurable Event in Protocols 5.8. • For deviations +/ -0 .0613 Hz, 282 MW / 0.1 Hz should be used as the standard minimum. • With a 420 MW / 0.1 Hz frequency response standard, the appropriate SCE deadband is one that covers the large majority of typical system control errors, such as the greater of 2% of QSE scheduled load or 12 MW. • ROS recommended the last two bullets of the PRS charge be addressed by WMS

7. more PRS action • On 7/21/05 PRS remanded PRR 586 to WMS with the following motion: • PRS refers PRR586 to WMS to consider frequency control problems identified by the PDCWG and ROS and develop commercial solutions, such as incentives that should be re-aligned. WMS should also consider the commercial implications of the global plan that ROS is being asked to develop to address those problems. PRS also requests that ROS continue its work related to frequency control and develop a concrete global plan, including prioritized actions and a timeline, to address the frequency issues it identified. In addition, ROS should complete the analysis of primary and secondary response issues it identified.

8. Frequency Control TF Charge • WMS formed the FCTF in response to the significant number of PRRs filed to address SCE calculation methodology, performance measurement, and compliance. • The TF was never formally charged, but WMS determined the TF should take a “holistic” approach to examining the commercial structures, performance measures, incentives, and penalties needed to achieve satisfactory system frequency control. • The Frequency Task Force first met Aug. 2, 2005 to determine whether commercial solutions could be devised to improve system frequency control.

9. FCTF Issues Examined • Contribution of SCE to poor frequency control • Contribution of SCE to regulation deployment • Contribution of load forecast error to regulation deployment • Market obligations / incentives to provide primary frequency response • Market incentives / penalties for SCE Performance • Uncontrollable Renewable Resource Forecast Error • Re-evaluation of Protocols 6.10.5.3 (PRR 525) • Accuracy of ERCOT RGS signals and impact on QSE SCE calculation

10. Contribution of SCEto poor frequency control • Neither PRR 525 nor PRR 586 specifically addresses primary or secondary frequency response. Instead, each addresses SCE, which impacts the amount of Regulation Service deployed to maintain system frequency. • SCE is one of many factors contributing to poor system frequency control and the need for Regulation Service. • Other factors include: • ERCOT load forecast error / Real-time variations in load • Poor governor response

11. Contribution of SCEto regulation deployment • SCE is a contributor but not necessarily a large driver for Regulation Service procurement and deployment. • Allocation of some portion of RGS costs to QSEs with poor SCE (a la PRR 586) could provide appropriate incentive to maintain low SCE. • Allocation of RGS costs to QSEs with poor SCE should be proportional to SCE impact.

12. Market obligations / incentivesto provide primary frequency response • Operating Guides require all generators online to place their governors in service • The FCTF is thus far unable to determine whether ERCOT is getting adequate governor response • ERCOT is an “energy only” market in which generators have neither an obligation nor an incentive to reserve capacity for frequency response. • In fact, the reverse is true – the market structure incentivizes generators to maximize production from units online, sometimes leaving little room for machines to respond to frequency excursions

13. Market incentives / penaltiesfor SCE Performance • Pre-PRR 525: CPS2 performance measure provided incentive for resource QSEs to not bid Regulation Service during intervals with high SCE. • Post-PRR 525: “Death Penalty” provides strong incentive to minimize SCE • Especially for ancillary service providers • Affects all resources, which must maintain DBES obligation • Inability to make mandatory DBES offer violates PUCT Rule • Jeopardizes PGC registration

14. Uncontrollable Renewable ResourceForecast Error • URR schedules based on resource forecast • Historically poor forecasting performance by URRs • URR SCE contributes to regulation deployment • Holding an uncontrollable resource to control performance standard makes little sense and, in fact, provides a disincentive for the market to meet a statutory obligation to install URRs in Texas • “Persistence Forecasting” methodology explored to improve URR SCE and minimize system impacts

15. Persistence Forecasting Methodology

16. Re-evaluation of Protocols 6.10.5.3 (PRR 525) • Monitoring and evaluating SCE Performance scores under PRR 525 metric. • No recommendation but it is safe to say nearly everyone agrees with one of the three following statements: • PRR 525 does not use a good performance measure • SCE Compliance penalty structure is inappropriate • Both the of statements above are true • Some changes to the exemption list are in order

17. ERCOT’s CPS1 12 MonthRolling Average Trend

18. ERCOT CPS1 by Interval

19. March MTD CPS1 by Interval

20. QSE PRR525 10-MinuteInterval Scoring

21. 525 Passing 10-Min Interval Percentage Trends

22. Accuracy of ERCOT RGS signals and impact on QSE SCE calculation • TXU supplied data suggesting frequent implied ramp rate violations in ERCOT URS and DRS signals • ERCOT agrees a problem exists. ERCOT system apparently randomly skips an AGC cycle, resulting in the next value being higher or lower than it should • ERCOT staff agrees this has some impact on QSE SCE calculation • ERCOT system analysis and applicability to other QSEs ongoing

23. Framing the Issues • Group issues into 3 categories • Address SCE performance measure calculation and/or penalty structure before July 1 “death penalty” deadline • Address the “low-hanging fruit” clean up items related to SCE performance measure • Address incentives / penalties / performance measures for primary frequency response

24. Options • PRR 656: SCE Performance Charge (Cat. 1) • Draft PRR: SCE Compliance Enforcement (Cat. 1) • Draft PRR: Ancillary Service Deployment Performance Conditions (Cat. 2) • Draft SCR: Persistence Forecasting Methodology for URRs (Cat. 2) • Draft PRR: Governor Response Service (Cat. 3)

25. Option 1PRR 656: SCE Performance Charge • Addresses both SCE calculation methodology and enforcement regime • Creates an SCE Performance Charge to replace current SCE Performance Monitoring • QSEs will be charged for each 5-minute interval for SCE average outside their deadband that contributes to Regulation Service deployment

26. Option 2Draft PRR: SCE Compliance Enforcement • Basically keeps the PRR 525 SCE calculation methodology intact • Substitutes alternate penalty structure for existing “death penalty only” regime • Poor performing QSEs ability to offer Regulation Service “ratcheted down” following failure to meet SCE performance measure.

27. Option 3Draft PRR: Ancillary Service Deployment Performance Conditions • Addresses the “low-hanging fruit” • Amends Protocols 6.10.6 • Exempts URRs from SCE enforcement regime • Clarifies ramp rate violation impacts in QSE SCE calculation • Clarifies intent behind unit trip exemption from QSE SCE calculation

28. Option 4Draft SCR: Persistence Forecasting Methodology for URRs • System changes required to implement persistence forecasting • Question about whether QSEs should submit performance data or whether ERCOT should capture and utilize data on behalf of QSEs • Changes to Lodestar, SPD likely • SCR development ongoing

29. Option 5Draft PRR: Governor Response Service • FCTF discussed bid-based service, pay-as-you-go service, and governor response performance measure • Service to provide primary frequency response • As a bid-based service it would be treated similar to how RRS is treated today. Offers from generation resources would take the form of “MWs/0.1 Hz deviation” and those offers struck would get a capacity payment for the amount of MWs struck in the Day Ahead ancillary service procurement process.

30. Option 5Draft PRR: Governor Response Service • As a “pay-as-you-go” service, the generation resource presumably offers in some amount of “MWs/0.1 Hz” value and be paid nothing in the DA A/S procurement process. • Payment would only occur if a frequency event actually occurred in real time. Then some yet to be proposed “look back” approach would be used for settlements. Payments could be paid on a capacity basis (using RRS as proxy value?, just the hour of the event/all day?) or on a flat fee basis using some other value as a proxy.

31. Next Steps • Next FCTF meeting on 3/31/06 • Refine options into recommendations • Request action to address Category 1 Issues • Request action to address Category 2 Issues • Determine next steps to address Category 3 Issues • Address pending PRRs 586, 605, 607, and 608 • Next ROS meeting on 4/13/06 • Comment on FCTF recommendations • Next WMS meeting on 4/19/06 • Comment on FCTF recommendations • April 21 PRS meeting • Vote on FCTF-submitted PRRs (Urgent Status requested)